Lobbyists, Governments and Public Trust ImPLemenTInG The ... · Lobbyists, Governments and Public...

Lobbyists, Governments and Public TrustVoLume 3

ImPLemenTInG The oeCD PrInCIPLes for TransParenCy anD InTeGrITy In LobbyInG

Lobbyists, Governments and Public TrustVoLume 3ImPLemenTInG The oeCD PrInCIPLes for TransParenCy anD InTeGrITy In LobbyInG

HIGHLIGHTS

Contents

Foreword

Acknowledgments

Executive summary

Why address lobbying risks and concerns now?

Governments are shedding more light on lobbying

Addressing emerging concerns on integrity

The way forward: capitalising on the OECD principles to further reinforce a fair and inclusive decision-making process

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HIGHLIGHTS

FOREWORD – 1

LOBBYISTS, GOVERNMENTS AND PUBLIC TRUST VOLUME 3: LESSONS LEARNED FROM IMPLEMENTING THE OECD PRINCIPLES ON TRANSPARENCY AND

INTEGRITY IN LOBBYING: HIGLIGHTS © OECD 2014

Foreword

Citizens’ trust in government provides the foundation for good governance and

effective policy-making. This is especially true in the current post-crisis context in which

structural reforms involve difficult choices, and where the confidence of citizens and

markets is critical for fostering economic and social development. However, public

opinion surveys suggest that trust in government is waning in most OECD member

countries. This is partly due to the perception that policy decisions are driven by private

interests at the expense of the public good.

Lobbying is a fact of public life in all countries. It has the potential to promote

democratic participation and can provide decision makers with valuable insights and

information, as well as facilitate stakeholder access to public policy development and

implementation. Yet, lobbying is often perceived as an opaque activity of dubious

integrity, which may result in undue influence, unfair competition and regulatory capture

to the detriment of fair, impartial and effective policy making.

To level the playing field among all stakeholders in the policy-making process, the

OECD adopted in 2010 the Recommendation on Principles for Transparency and

Integrity in Lobbying – the sole international instrument aimed at mitigating lobbying-

related risks of corruption and undue influence. This report takes stock of progress made

by OECD member countries in implementing the Principles and shows that, while

progress has been made in a number of countries, more is needed to safeguard the

government decision-making process across most OECD member countries.

There is evidence of an emerging consensus on the need for transparency. Fourteen

OECD member countries have introduced lobbying regulations to this effect, and others

are considering to do so. More countries have introduced regulation in the past five years

than in the previous 60. While this is a significant step forward, lobbying regulation has at

times been scandal-driven instead of forward-looking, with questionable cost-benefit

outcomes. The resulting regulations are sometimes incomplete and do not fully meet the

expectations of legislators and lobbyists as to what should be disclosed, the adequate

level of transparency, and options for managing lobbying systems once they are in place.

Promoting compliance and enforcement is proving to be a particular challenge.

Enforcement of codes of conduct and integrity standards remains relatively low, and the

bulk of surveyed lobbyists indicate that there are either no sanctions for breaching codes

of conduct or, if there are, they are not compelling enough to deter breaches. An

additional challenge is that of poor coordination of transnational lobbying practices,

which results in different requirements for the same actors in different jurisdictions.

Moving forward, this report also suggests how the OECD Principles can be applied in

practice to promote greater trust and improve the quality of decision making. Since it

takes two to lobby, both governments and lobbyists need to take their share of

responsibility. In the case of governments, it is crucial to strengthen the implementation

of the wider integrity framework and adapt it to evolving and emerging risks.

2 – FOREWORD



Furthermore, in order to measure costs, identify benefits and monitor performance of

lobbying regulations and frameworks, countries would benefit from identifying relevant

data, benchmarks and indicators relative to transparency in lobbying, the public

decision-making process and, ultimately, the broader integrity framework. Finally, the

review identifies a need to revisit and take stock of policies for managing conflict of

interest to ensure that revolving door practices, as well as the unbalanced representation

and influence of advisory groups, are effectively mitigated.

Addressing concerns related to lobbying practices and undue influence in the

decision-making process is a key lever for restoring trust in government. This report will

contribute to the OECD’s broader efforts in helping governments regain public

confidence, not only in the area of lobbying, but also in regulation, conflict of interest and

campaign financing. Securing fairness in policy making and building solid foundations to

ensure that public institutions serve the public interest are essential to advance better

policies for better lives.

Angel Gurría

OECD Secretary-General

ACKNOWLEDGEMENTS – 3



Acknowledgments

This review was prepared by the Public Sector Integrity Division of the Public

Governance and Territorial Development Directorate.

Under the guidance of Janos Bertók, the coordination and drafting of this report was

led by Ulrika Kilnes. Invaluable input and guidance was provided by Julio Bacio

Terracino. Data cleaning and follow-up were carried out by Maria Emma Cantera. The

report was edited by Ken Kincaid. Administrative assistance in preparing the report was

provided by Sophie Limoges, Sarah Michelson, Sophie O’Gorman, and Anastasia

Slojneva.

Particular appreciation goes to the respondents of the three OECD surveys on

lobbying that were conducted in 2013 – namely government officials from 26 OECD

member countries and Brazil, over 100 lobby associations and lobbyists from 16 member

and partner countries, and legislators from 14 member and partner countries. Particular

appreciation goes also to those that actively participated in the consultation on the

findings of the review during the OECD High-Level Forum on Transparency and

Integrity in Lobbying on 27-28 June 2013 and the OECD High-Level Parliamentary

Seminars held in Santiago (Chile) on 8 9 March 2012 and in Paris (France) on 2 October

2013. Special thanks go to Pier Carlo Padoan, Former OECD Deputy Secretary General

and Chief Economist, and Maroš Šefčovič, Vice-President of the European Commission,

European Commissioner for Inter-Institutional Relations and Administration, who opened

the OECD High-Level Forum on Transparency and Integrity in Lobbying, as well as the

speakers, namely: Micol Bertoni, Public Affairs Community of Europe; Adam Bramwell,

General Counsel to the Secretary of the Senate, United States; John Evans, General

Secretary, Trade Union Advisory Committee to the OECD; Susanna di Feliciantonio,

President, Society of European Affairs Professionals; Don W. Fox, Principal Deputy

Director of the United States Office of Government Ethics; Christian Humborg,

Managing Director, Transparency International Germany; Dr. Peter Köppl, Vice-

President, Austrian Public Affairs Association; Gérard Legris, Coordinator of EP-COM

Joint Secretariat of the Transparency Register; Robert Mack, Vice-chair, European Public

Affairs Consultancies' Association; Giuseppe Mazzei, Public Affairs Community of

Europe; Rok Praprotnik, Deputy Chief-Commissioner, Commission for the Prevention of

Corruption, Republic of Slovenia; Krzysztof Przemieniecki, Ministry of Interior, Poland;

Wolfgang Rau, Executive Secretary of the Group of States against Corruption, Council of

Europe; José Luis Rufas Quintana, European Parliament Secretariat General; Judge of the

District Court Leoben Dr Thomas Schoditsch, Austrian Federal Ministry of Justice;

Karen E. Shepherd, Commissioner of Lobbying of Canada; Sebastián Soto, Head of the

Juridical-Legislative Division, Ministry of the Presidency of Chile; Aine Stapleton,

Government Reform Unit of the Department of Public Expenditure and Reform, Ireland;

Thomas M. Susman, Director of Governmental Affairs, American Bar Association; Marie

Thiel, Administrator, European Parliament, DG Presidency, Transparency Unit; Alex

Thomas, Deputy Director, Elections and Parliament Division, United Kingdom Cabinet

Office; Lyn Trytsman-Gray, Senior Vice President, European Affairs at RTL Group; and

Bernhard Welschke, Secretary General, Business and Industry Advisory Committee to

the OECD.

4 – ACKNOWLEDGEMENTS



The Public Governance Committee and the Public Sector Integrity Network reviewed

the progress made in OECD member countries in the autumn of 2013. The OECD

Council adopted the monitoring report on 12 March 2014.

TABLE OF CONTENTS – 5



Table of contents

Executive summary .......................................................................................................................... 7

Policy directions ......................................................................................................................... 8

I. Why address lobbying risks and concerns now? ................................................................. 11

Lobbying is central to dwindling trust in government .............................................................. 11 Lobbying may result in undue influence, unfair competition, and regulatory capture ............. 13 Transnational lobbying practices raise new global concerns .................................................... 14

II. Governments are shedding more light on lobbying ............................................................. 16

More countries have regulated lobbying in the past five years than in the previous sixty ....... 17 Regulation has been reactive and scandal-driven instead of forward looking .......................... 19 Concerns, scandals, and political will generally determine levels of transparency .................. 19 Countries struggle with balancing the administrative costs of transparency mechanisms ....... 21

III. Addressing emerging concerns on integrity .......................................................................... 22

Operational public sector integrity frameworks are essential to the mitigation of

lobbying risks ........................................................................................................................... 23 Although it takes two to lobby, lobbied officials are responsible for safeguarding

the public interest and rejecting undue influence ..................................................................... 25 The “revolving door” is a major risk to the integrity of public decision making ..................... 26 Insider lobbying: influence of private interests through advisory groups

is an emerging concern ............................................................................................................. 32 Measuring the costs and benefits of enhancing transparency and integrity in lobbying

remains a challenge .................................................................................................................. 35

IV. The way forward: capitalising on the OECD principles to further reinforce a fair

and inclusive decision-making process ................................................................................. 36

Continue efforts to address lobbying concerns and risks in the decision-making process

as a key policy lever for fostering trust .................................................................................... 37 Invest in measuring benefits and costs and monitoring performance ....................................... 38 Identify and promote innovative integrity frameworks that reflect the needs

and concerns of countries in the 21st century ........................................................................... 38 Review policies for managing conflict of interest in revolving door practices and

the unbalanced representation and influence of advisory groups ............................................. 39

EXECUTIVE SUMMARY – 7



Executive summary

This report reviews how risks and concerns related to lobbying have evolved and

identifies lessons learned in designing and implementing measures and cost-effective

solutions for safeguarding the integrity of the decision-making process. This contributes

to the OECD Strategy on Trust – adopted by Ministers at the OECD Ministerial Council

Meeting in May 2014 – which includes a module on “Securing fairness in policy

making”, in which curbing policy capture by private interests and ensuring political

participation is a main element.

On 18 February 2010, the OECD Council adopted the Recommendation of the

Council on Principles for Transparency and Integrity in Lobbying. The Public

Governance Committee (PGC) had led the development of the Recommendation which

remains the only international instrument to address concerns over lobbying practices,

offer guidance on how to meet expectations of transparency and accountability, and

support a level playing field in public decision making. When adopting the

Recommendation, the Council requested that the PGC report back to it on progress made

in implementing the Recommendation in three years and regularly thereafter in

consultation with the Regulatory Policy Committee and other relevant Bodies.

Three years later, the PGC is now taking stock of the progress made in implementation by

OECD member countries and key and other partner countries.

The findings of this review show that lobbying is a fact of life in the public decision-

making process. It can provide decision-makers with valuable insight and data and

facilitate stakeholders’ access to the development and implementation of public policies.

However, it can also lead to undue influence, unfair competition, and regulatory capture

to the detriment of the public interest and effective public policies.

Improving the transparency and integrity of the public decision-making process,

particularly by using regulation to address concerns over lobbying, has been high on

many governments’ agendas in the past three years. More countries have introduced

regulation in the past five years than in the previous 60. Experience shows, however, that

in most cases regulation has been reactive and scandal-driven instead of forward looking.

Consequently, strong transparency measures designed to foster trust in public decision

making have too often resulted in overshooting, whereby countries have over-zealously

addressed concerns. Many have also struggled with balancing the administrative cost of

transparency mechanisms. Nevertheless, lobbying regulation has generally created more

openness and transparency in lobbying practices.

Although 41% of OECD member countries have acted to set or tighten lobbying

standards, the process of doing so has not been without its challenges. Some have

amended laws that were already in place while others, which enacted new regulations that

were repealed, had to legislate again at a later date. More seasoned regulators of the

lobbying industry, like the United States and Canada, have updated their rules. The

process of approving legislation on lobbying has also been both complex and lengthy in

countries, sometimes requiring several rounds of voting and having to overcome

significant legislative hurdles.

8 – EXECUTIVE SUMMARY



Countries have also struggled to implement lobbying regulations and there are still

shortcomings in compliance and enforcement strategies. Enforcement of integrity

standards and codes of conduct remains relatively weak and most lobbyists surveyed by

the OECD indicated that there were either no sanctions for breaching standards or codes

of conduct or, if there were, that they were not compelling enough to deter breaches.

Although compliance among public officials is usually promoted through awareness

raising and training, greater efforts to educate them are required. Legislation generally

incorporates sanctions for public officials, although there is limited information on

whether they are applied.

While countries have increasingly opted to regulate lobbying practices, experience

has shown that streamlining lobbying regulations into the wider integrity framework

remains central to addressing lobbying-related risks effectively. There is a general

consensus that while it takes two to lobby, the main responsibility for safeguarding the

public interest and rejecting undue influence lies with those who are lobbied, and

therefore a sound public-sector integrity framework is essential.

Furthermore, countries’ experience in the last three years has revealed new or

heightened risks related to lobbying that demand special attention and an innovative,

modern integrity framework. Revolving-door practices and, in particular, pre-public

employment risks continue to threaten the integrity of public decision making.

Only one-third of OECD member countries place any restrictions on hiring lobbyists to

fill regulatory or advisory posts in government. Similarly, the influence of private

interests through advisory groups has emerged as a growing concern. Although members

of advisory groups have direct access to decision makers and are therefore able to lobby

from the inside, such groups are not generally required to ensure a balanced

representation of interests in their make-up.

Good governance requires assessment and data, and lobbying is not an exception.

Yet, most countries struggle to measure the costs and benefits of enhancing transparency

and integrity in lobbying and have trouble monitoring the performance of measures in

place. Collecting data on the costs and benefits for government and lobbyists alike is key

to better understanding lobbying in different country contexts, to assessing whether

measures taken meet their intended objectives, and to deciding if money could be better

spent elsewhere. Despite the availability of technology which considerably reduces the

burden of collecting and analysing quantitative data, there is little lobbying data available

in most countries.

Policy directions

Focus efforts on the implementation of the Recommendation on Principles for

Transparency and Integrity in Lobbying to strengthen confidence in the public

decision-making process and restore trust in government.

Identify relevant data, benchmarks, and indicators relative to transparency in

lobbying, the public decision-making process and, ultimately, the broader

integrity framework in order to measure costs, identify benefits, and monitor

performance.

EXECUTIVE SUMMARY – 9



Strengthen the implementation of the wider integrity framework, as it is the prime

tool for safeguarding transparency and integrity in the decision-making process in

general and lobbying practices in particular. Countries could seize the opportunity

to reflect on new integrity challenges and constraints and identify innovative and

cost-effective measures.

Review policies for managing conflict of interest to ensure that revolving door

practices and the unbalanced representation and influence of advisory groups are

effectively mitigated. Countries would benefit from highlighting and sharing good

practices so as to identify the conditions for policies and practices that effectively

safeguard the integrity of the public decision-making process and contribute to

building trust in government.

10 – LOBBYISTS, GOVERNMENTS AND PUBLIC TRUST



I. WHY ADDRESS LOBBYING RISKS AND CONCERNS NOW? – 11



I. Why address lobbying risks and concerns now?

Lobbying can be a valuable component in the public decision-making process. In an

increasingly complex policy landscape, it may afford decision-makers valuable insights

and data and stakeholders access to public policy development and implementation.

Yet, in practice, lobbying is also a global multi-billion dollar business and a source of

concern for policy makers and citizens alike. Since the adoption of the Recommendation

of the OECD Council on Principles for Transparency and Integrity in Lobbying (known

as “the Recommendation”) in February 2010, a growing number of OECD member and

partner countries have been discussing lobbying in the political and policy arena and its

part in economic crises, elections, scandals, and dwindling trust in governments.

Lobbying is central to dwindling trust in government

Available data suggest that trust in the public decision-making process and in

governments in general is waning in the vast majority of OECD countries

(OECD, 2013a). Citizens express doubts about their governments’ ability to make the

right decisions. There is a widespread view that governments are not able to effectively

regulate markets, that business exerts undue influence over public policy, and that the

distribution of burdens and rewards across society is unfair. Indeed, the global financial

and economic crisis highlighted serious failures of governance – from revolving doors to

conflicts of interest and regulatory capture. Such mistrust is heightened by concerns over

fairness in fiscal consolidation and in the sacrifices required by structural reform.

This sentiment was confirmed in the debates at the OECD Forum on Transparency and

Integrity in Lobbying in June 2013. Participants emphasised that:

an underlying question countries face is that of fairness;

there is a crisis of confidence; and

a major problem at the heart of the democratic system is a sense that the wealthy

finance political parties only to further their own interests.

Indeed, changes in the perceived transparency of public decision making are strongly

correlated with changes in trust (see Figure 1). The 2013 Edelman Trust Barometer found

that about half of the respondents surveyed in 26 countries distrusted government.

Amongst the key factors they cited to explain the prevailing distrust were “wrong

incentives driving policies” and “corruption/fraud”. Together, the two factors accounted

for half of all reasons for trusting government less. They point to an urgent need to

address the credibility of the bodies formally involved in public decision making and to

strengthen the underlying institutional conditions that shape the decision-making process.

Answering that need requires looking into lobbying practices so as to ensure fair decision

making and a level playing field for all the stakeholders seeking to influence the process.

12 – I. WHY ADDRESS LOBBYING RISKS AND CONCERNS NOW?



Figure 1. Correlation between public trust in politicians and transparency in government

policymaking, 2013

Source: World Economic Forum (WEF) (2013), Global Competitiveness Report 2013-2014, World Economic Forum,

Geneva, www3.weforum.org/docs/WEF_GlobalCompetitivenessReport_2013-14.pdf.

Lobbyists and legislators surveyed in 2013 in two OECD surveys widely shared the

opinion that transparent lobbying would increase citizens’ trust in the decision-making

process. Most respondents (74% of lobbyists and 68% of legislators) expressed their

agreement or strong agreement, which suggests that addressing concerns over

transparency in lobbying (e.g. deals behind closed doors) could be a key policy lever for

restoring trust in governments (Figure 2).

Developing an adequate framework that enhances transparency and accountability in

lobbying so as to foster trust in government begins with countries clarifying public

concerns. A careful analysis should take into account all available options – policy

measures, legislation, and voluntary or mandatory regulation – with the aim of drawing

up a proposal that adequately addresses concerns within each country’s socio-political

and administrative context.

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Figure 2. Transparent lobbying increases citizens’ trust in the public decision-making process

Source: OECD 2013 Survey on Lobbying for Lobbyists and OECD 2013 Survey on

Lobbying for Legislators.

Lobbying may result in undue influence, unfair competition, and regulatory capture

Lobbying is perceived in most countries as a mechanism for perpetuating special

interests at the expense of the public interest. Indeed, the literature has demonstrated that

the disproportionate, unregulated influence of interest groups may lead to state capture

(Kaufmann, Hellman and Geraint; 2000). In a 2013 Burson-Marsteller survey 24% of

politicians and senior officials across 20 European countries said that the worst aspect of

lobbying was that it gave undue weight to elites and the wealthy, while 14% considered

that it facilitated undue influence in the democratic process. As many as 55% of

respondents in Norway and 40% in Hungary believed that lobbying favoured the rich and

powerful, while the figure was 33% in the Czech Republic, 26% in Greece, and 24% in

France.

Legislators and lobbyists themselves harbour similar suspicions and negative

perceptions. The number of lobbyists who believe that inappropriate influence-peddling

in their trade is a frequent problem increased significantly between 2009 and 2013

(Figure 3).

Suspicion of lobbying is widely fuelled by real-life instances. Cases of undue influence

in public decision-making processes and regulatory capture to the detriment of the public

interest have surfaced in a number of countries. Informed opinion has voiced the view that

certain economic crises were partly caused by the influence of specific interests on

government decision-making. For example, an IMF working paper published in 2009 links

intensive lobbying by the financial, insurance and real estate industries in the United States

(US) with high-risk lending practices (Igan, Mishra and Tressel, 2009).1 The paper reveals

how lenders who lobby more intensively on the issues of mortgage lending and

securitisation have (i) more lax lending standards measured by loan-to-income ratios,

1 OECD (2013c) addresses the same issue.

42%

26% 26%

5%0%

38%36%

16%

8%

2%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Strongly agree Agree Neutral Disagree Stronglydisagree

Legislators

Lobbyists




(ii) a greater tendency to securitise, and (iii) faster-growing mortgage loan portfolios. In

other words, lenders who lobby engage in riskier lending (ibid.).

Not only does the public at large pay the price of undue influence and regulatory

capture, but fair market competition also suffers. Without adequate safeguards, lobbying

may result in the de facto abuse of dominant market positions – and even quasi-

monopolies – by those companies that have the necessary wealth and right connections.

The undoubted upshot is more costly goods and services for consumers and negative

impacts on countries’ economic performances.

Figure 3. Inappropriate influence-peddling by lobbyists – e.g. giving gifts to obtain favours from

officials or misrepresenting issues – is a frequent or occasional problem

Note: Respondents were asked: “Generally speaking, do you think that inappropriate influence-peddling by

lobbyists, such as seeking official favours with gifts or misrepresenting issues, is a problem?”

Source: OECD 2013 Survey on Lobbying for Lobbyists, OECD 2009 Survey on Lobbying and OECD 2013

Survey on Lobbying for Legislators.

Transnational lobbying practices raise new global concerns

In 2013, the OECD conducted a review of how countries had implemented the

Recommendation of the Council on Principles for Transparency and Integrity in

Lobbying in the previous three years. The monitoring review showed that lobbying

practices are evolving. As globalisation and interdependency between countries have

increased dramatically in recent years, lobbying strategies and practices have become

more transnational. For example, US corporations now regularly lobby the European

Parliament and Commission to influence decision-making in the European market, which

in turn has an impact on the United States market. Similarly, lobbyists may be active in

one or more European country and simultaneously lobby supranational institutions.

The convergence and emergence of such global practices has spawned new concerns and

risks. Who is shaping them?

36%

21.4% 21.4% 21.4%

0%

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19%

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14.9%

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20%

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35%

40%

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Yes, it is afrequent problem

Somewhat, it is anoccasionalproblem

Not really, thereare very few such

cases

No, as far as Iknow, it almostnever happens

No, suchbehaviour is not

inappropriateinfluence-peddling

Legislators

Lobbyists (2009)

Lobbyists (2013)




Disparate rules and degrees of transparency across different countries and

jurisdictions favour the proliferation of lobbying practices and inconsistent international

responses. In addition, different rules for the same actors in different jurisdictions may

not only result in different levels of influence, but in uneven playing fields depending on

the jurisdictions in which lobbyists operate. Transnational lobbying raises questions of

transparency and competition at a global level. Accordingly, countries should give special

attention to cross-border lobbying practices and also address them at the global and

supranational levels. To that end, they would benefit from coming together with regional

and international institutions in coalitions that incorporate multi-level governance

processes.

II. GOVERNMENTS ARE SHEDDING MORE LIGHT ON LOBBYING – 17



II. Governments are shedding more light on lobbying

Improving the transparency and integrity of the public decision-making process,

particularly by using regulations to address concerns over lobbying, has been high on

many governments’ agendas in the past three years – and continues to be so today.

Although scandal has driven the growth in regulation in most cases, the result has

nevertheless been more openness, information and transparency in lobbying practices.

More countries have regulated lobbying in the past five years than in the previous

sixty

The aforementioned concerns have prompted more and more countries to opt for the

regulation of lobbying. Their experiences show that the Recommendation of the Council

on Principles for Transparency and Integrity in Lobbying (the Recommendation) has been

essential in helping them to develop their regulations in the past four years.

From the 1940s to the early 2000s (Figure 4), only four countries regulated lobbying

practices. Since 2005 an additional ten countries have followed suit. Regulations may be

mandatory systems – as they are in Canada and the United States (US), for example – or

voluntary schemes, as in France. A number of countries, such as Ireland, have legislation

on lobbying in the pipeline.

Although 41% of OECD member countries have acted to tighten lobbying standards,

doing so has not been without its challenges. Some have amended statutory or regulatory

provisions that were already in place, while others have enacted new ones only to see

them repealed, before legislating or regulating once more at a later date. Australia, for

instance, first regulated lobbying through the Lobbyist Registration Scheme of 1983

before it abolished the scheme in 1996. Its current Lobbying Code of Conduct, introduced

in 2008, also establishes a lobbyist register. Similarly, Hungary introduced Act XLIX on

Lobbying Activities in 2006, repealed it in 2011, then brought in an integrity management

regulatory system for state administration bodies and lobbyists in February 2013.2

Some countries have endured complex, lengthy struggles to secure approval for

legislation on lobbying, sometimes having to take it through several rounds of voting and

overcome significant legislative hurdles. Mexico, for example, has regulated lobbying in

the legislative branch since 2010, but only after years of parliamentary debate dating back

to 2002.

More seasoned regulators of the lobbying business like the US and Canada updated

their bodies of law. The US replaced the Federal Regulation of Lobbying Act of 1946 by

the 1995 Lobbying Disclosure Act, while Canada has made several amendments to its

Lobbyists Registration Act of 1989 and supplemented it with the Lobbying Act of 2008.

On 27 February and 26 June 2013, the Bureau of France’s National Assembly adopted a

new regulation that restated the terms of relationships between députés and

representatives of interest groups. Among other things, the regulation strengthened the

2 Magyar Közlöny 30. Szám (2013. február 25).

18 – II. GOVERNMENTS ARE SHEDDING MORE LIGHT ON LOBBYING



reporting requirements that had been in place since 2009 and made registration legally

binding.

Figure 4. OECD countries are increasingly opting to regulate lobbying3

Nevertheless, most OECD countries do not regulate lobbying. Over half (56%) of the

politicians and senior officials4 from 20 European Union (EU) countries surveyed by

Burson-Marsteller in 2013 were of the opinion that lobbying was not sufficiently

regulated in their countries. The percentage of respondents who held that view was

particularly high in countries – such as Portugal (100%), Spain (93%), the Czech

Republic (88%), and Italy (87%) – where the government has not yet regulated lobbying.

However, half or more of the decision makers questioned in Norway (59%), Denmark

(57%) and Poland (50%) felt that lobbying was amply regulated.

3 Australia: Lobbying was first regulated in Australia through the Lobbyist Registration Scheme of 1983, but the scheme was

abolished in 1996. The current Lobbying Code of Conduct – which also established a lobbyists’ register – was introduced in 2008.

Canada: The Lobbyists Registration Act of 1989 has been amended several times and in 2008 was renamed the Lobbying

Act.

Chile: Chile enacted a law regulating lobbying in January 2014. However, this report refers to laws and practices adopted

until December 2013 and therefore Chile’s law is not analysed.

France: On 27 February and 26 June 2013, the Bureau of the French Assemblée Nationale – on the proposal of Mr Christophe Sirugue, President of the Delegation responsible for interest representatives – adopted a new regulation that

restated the terms of relationships between députés and representatives of interest groups.

Germany: Lobbying was first regulated through Article 73 of the Rules of Procedure of the German Bundestag in 1951.

Hungary: Hungary introduced Act XLIX on Lobbying Activities in 2006, repealed it in 2011, then brought in an integrity

management regulatory system for state administration bodies and lobbyists in February 2013 (Magyar Közlöny 30. Szám

[2013. február 25]).

Italy: With Ministerial Decree No. 2284 of 6 February 2012, the Italian Ministry of Agricultural, Food and Forestry

Policies regulated stakeholders’ participation in the decision-making process of drafting bills and regulations under its

authority. In addition to the ministry’s regulation of lobbying, three Italian regions have introduced rules on the transparency of political and administrative activities, namely Toscana (2002), Molise (2004) and Abruzzo (2010).

Poland: The Act on Legislative and Regulatory Lobbying was passed by the Sejm (Lower House of Parliament) in July

2005. The Act was amended in 2011.

United Kingdom: The United Kingdom enacted the Transparency of Lobbying, Non-Party Campaigning and Trade Union

Administration Act 2014 in January 2014.

United States: The Federal Regulation of Lobbying Act of 1946 was replaced in 1995 by the Lobbying Disclosure Act.

4 Interviewees included politicians (members of national legislatures and Members of the European Parliament) and senior officials from national governments and the EU institutions. In total, nearly 600 interviews were conducted.




Regulation has been reactive and scandal-driven instead of forward looking

With a consensus among stakeholders and decision makers that lobbying should be

regulated and that currently it is not sufficiently regulated, the growing number of

countries opting to regulate lobbying is an encouraging sign. To date, however, most have

introduced or reformed lobby regulations on an ad hoc basis and largely in response to

political scandals. At times, therefore, strong transparency responses designed to foster

trust in public decision-making have resulted in over-regulation.

Building the necessary consensus among stakeholders before scandals take place and

harnessing enough political support has been difficult. However, experience shows that it

has been less of a challenge in countries that have taken a more forward-looking,

incremental approach. In light of concerns over lobbying and public decision making and

citizens’ waning trust, governments would benefit considerably from an approach that is

less reactive or scandal-driven.

Concerns, scandals, and political will generally determine levels of transparency

A common feature of lobbying regulations is that they require lobbyists to disclose

information about their practices and business through a register that serves as a platform

to manage disclosed information. Of the 26 countries that responded to the OECD’s

Survey on Lobbying Rules and Guidelines 9 of them – namely Austria, Canada, France,

Germany, Italy (Ministry of Agriculture), Mexico, Poland, Slovenia and the United States

– have lobbyist registers in place (Figure 5).

Figure 5. Lobbying registers in place in OECD countries

Note: Italy’s responses refer to the register operated by the Ministry of Agriculture.

No: 64%

Yes: 36%




Germany’s response refers to the public list of associations that lobby the German Federal Parliament

(Bundestag) or Federal Government and is kept by the President of the Bundestag.

There is no information available for Japan.

Source: OECD 2013 Survey on Lobbying Rules and Guidelines.

So as to promote informed decision making and enable scrutiny, registers should

contain information that is ample and relevant, to shine a light on lobbyists and key

aspects of lobbying activities. There is less chance of influence peddling in an open,

transparent decision-making process where information on who seeks to influence which

policies is publicly available. However, any supplementary disclosure requirements

should take into consideration the legitimate information needs of key players in the

public decision-making process. Countries with lobbying registers commonly require

lobbyists (and lobby firms) to publicly disclose their names, their contact details, their

employer’s name, and who their clients are (Figure 6).

However, the amount and type of information disclosed and made publicly available

varies widely depending on the resources available to run a lobbying register, a country’s

particular concerns, and the maturity of the system in place. For example, Canada and the

United States – which have had lobbying registers in place for longer than most OECD

countries – generally disclose more information than countries with more recent

regulations. Experience shows that concerns over lobbying (often prompted by scandal)

and political will are the factors that chiefly determine the transparency of lobbying

practices as measured by the amount, type, and availability of information disclosed.

Figure 6. Disclosure and public availability of lobbying information

Note: Data shows an aggregate of information from Australia, Austria, Canada, France, Germany, Italy (Ministry of

Agriculture), Mexico, Poland, Slovenia, the United States and the EP/EC Joint Transparency Register.


0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

names (of individuals or organisations)

contact details

whether the lobbyist was previously a public official

the names of clients

the name of the lobbyist employer

the name of parent or subsidiary company that would benefit from the lobbying…

the specific subject matters lobbied

the name or description of specific legislative proposals, bills, regulations,…

the name of the national/federal departments or agencies contacted

the source and amounts of any government funding received by the entity…

lobbying expenses

turnover from lobbying activity

the communication techniques used such as meetings, telephone calls,…

contributions to political campaigns

The information collected is publically available Information is collected but not made publically available Information is not collected




Countries struggle with balancing the administrative costs of transparency

mechanisms

A key challenge that governments face is that of striking a balance between collecting

and managing information on lobbying activities and reaping the benefits of doing so.

The administrative burden on lobbying oversight bodies of implementing rules and

guidelines and on lobbyists of complying with them, together with the annual cost of

running institutional support mechanisms, has led a number of countries to exclude some

types of activities from the scope of the regulation and, therefore, not to include them in

their registers. Worth highlighting is that, although many OECD countries have

introduced a number of arrangements to minimize red tape, Austria is so far the only one

to have calculated the regulatory burden on lobbyists of complying with rules. In the

Regulatory Impact Assessment which it conducted under the terms of the Lobbying Act,

the Federal Ministry of Justice came to the conclusion that the burden on lobbyists was

very light compared to their earnings.5

One ploy used by a number of countries – e.g. Canada, Slovenia, and the United

States – is not to register communication that is already on public record. This includes

formal presentations to legislative committees, public hearings, established consultation

mechanisms, or information related to the decision-making process already in the public

domain. The approach has effectively eased administrative burdens, avoided duplication,

and helped save money. In Slovenia, for example, records of meetings between senior

public officials and lobbyists are available under the Access to Public Information Act,

but are not included in the register.

In most OECD countries with registers, lobbyists who are defined as such by a

country’s statutory or regulatory rules may submit their registrations and

activity/spending reports online in order to lighten their administrative load and save time

and money (Table 1). Of lobbyists surveyed in 2013, over two-thirds (69%) said that it

took them 30 minutes or more to register. Electronic submissions also streamline the

work of lobbying oversight bodies, which manage and monitor the application of

lobbying rules.

Austria, Canada, and the United States have also established “thresholds” beyond

which lobbyists – i.e. individuals whose activities are within the ambit of those countries’

regulations and legislation – are required to register (Table 1). In this way, lobbyists and

lobbying oversight bodies are relieved of paperwork and anybody who lobbies on more

than an occasional ad hoc basis is registered. Canada’s Lobbying Act, for example,

exempts from its definition of in-house lobbyists those who spend under a certain time

lobbying and those whose work is not remunerated. According to Article 7(1)(b) of the

act, a person needs to register his or her lobbying “duties” if they “constitute a significant

part of the duties of one employee or would constitute a significant part of the duties of

one employee if they were performed by only one employee”. The Canadian

Commissioner of Lobbying has interpreted “significant” to mean 20% of one individual’s

time.

Contrary to the situation in many OECD countries, the majority of surveyed lobbyists

believe that lobbying activities below certain established time or remuneration thresholds

should be covered by lobbying rules and guidelines. While governments seek to define

5 See www.parlament.gv.at/PAKT/VHG/XXIV/I/I_01465/fname_232777.pdf.

http://www.parlament.gv.at/PAKT/VHG/XXIV/I/I_01465/fname_232777.pdf




who is a lobbyist concisely and cost-effectively, lobbyists believe that coverage needs to

be more all-embracing.

Table 1. Mechanisms in place to lessen the administrative burden for oversight bodies of implementing and

managing lobbying rules and guidelines in selected OECD countries

Note: In Italy, responses refer to the system put in place by the Ministry of Agriculture.


Electronic

submission of

registrations

Electronic

submission of

activity/spending

reports

Electronic

(automatic)

verification that

all information

was submitted

Below a certain

threshold in

terms of for

example time

spent on

lobbying,

lobbyists do not

need to register

Austria l l l

Canada l l l

France

Germany

Italy l l l

Mexico

Poland l

Slovenia l l l

United States l l l l

Total OECD9

Yes 6 5 3 3

No 3 4 6 6

III. ADDRESSING EMERGING CONCERNS ON INTEGRITY – 23



III. Addressing emerging concerns on integrity

While more and more member and partner countries have opted to regulate lobbying,

experience has shown that streamlining regulations into the wider integrity framework

remains crucial to mitigate such lobbying-related risks as undue influence and unfair

competition. The last three years, however, have shown that there are new and heightened

risks that demand special attention and the modernisation of integrity frameworks.

Operational public sector integrity frameworks are essential to the mitigation of

lobbying risks

Expectations of open and fair decision making have put mounting pressure on

governments to ensure that private interests do not improperly affect official decisions.

A sound integrity framework is essential to meeting those expectations. Accordingly,

countries have implemented a wide variety of mechanisms. They range from those

designed to promote a culture of integrity among decision makers and increase the

transparency of the decision-making process to ones that strengthen conflict of interests

management and others that protect whistleblowers and enable them to report

wrong-doing.

In OECD member countries, practice reveals that decision makers’ disclosure of

private interests continues to be an essential tool for managing conflicts of interest and

ensuring the integrity of public decision making (OECD, 2013a). Interestingly, the

private interests of decision makers that most preoccupy OECD countries, who either

prohibit them or require their disclosure, are “paid outside positions” and “gifts” – which

reflects concerns over the decision-making process and lobbying practices (Figure 7).

Moreover, many countries’ legislation or codes of conduct are increasingly setting

standards of conduct for dealings between public officials and lobbyists – a trend

supported by the vast majority of stakeholders. In the OECD’s 2013 survey on lobbying,

most of the lobbyists and legislators surveyed felt that rules – in the form of legislation,

codes of conduct, or guidelines – should govern lobbying (Figure 8).

A view to emerge at the OECD Forum on Transparency and Integrity in Lobbying in

June 2013 was that lobbying risks should be mitigated first and foremost – and sometimes

solely – through the proper implementation of a broader integrity framework.

The Netherlands, for example, argued that the debate and reforms may be focusing too

narrowly on transparency and lobbying registries while overlooking the fact that they are

a means to an end of a fair, inclusive decision-making process. In other words, regulating

lobbying is not the only way to address concerns and mitigate risks related to lobbying.

Even more important is the design and implementation of a sound public sector integrity

framework.

24 – III. ADDRESSING EMERGING CONCERNS ON INTEGRITY



Figure 7. Levels of disclosure of decision makers’ private interests in the three branches of

government and the public availability of disclosed information

Source: OECD 2012 Survey on Managing Conflict of Interest

Figure 8. Stakeholders believe that there should be rules on lobbying

Note: Respondents were asked: ”Do you believe that there should be rules/guidelines related

to lobbying in place?”

Source: OECD 2013 Survey on Lobbying for Lobbyists and OECD 2013 Survey on

Lobbying for Legislators.

0

10

20

30

40

50

60

70

80

90

100

Outside position:Paid

Gifts Outside position:Non-Paid

Assets Income Source Liabilities Income Amount PreviousEmployment

LOW

LEV

ELM

EDIU

M L

EVEL

HIG

H L

EVEL

68%

47%

26%

16%

43%46%

7%4%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Yes, there should belegislation on

lobbying in place

Yes, there should becodes of conduct on

lobbying in place

Yes, there should benon-legal

documents such asguidelines on

lobbying in place

No

Legislators

Lobbyists




Although it takes two to lobby, lobbied officials are responsible for safeguarding the

public interest and rejecting undue influence

Governments have the primary responsibility of regulating and controlling the

conduct of public officials who may be lobbied, as set out in the Principles of the

Recommendation. However, lobbyists and their clients also share a duty not to exert or be

swayed by illicit influence and to comply with professional standards of conduct –

particularly professionalism – when conducting their business.

As part of their responsibility, lobbyists have created professional groups to regulate

their own activities – generally on a voluntary basis through i) codes of conduct,

ii) registers, and/or iii) monitoring/enforcement systems.

Codes of conduct remain the principal tool of self-regulation. Of the lobbyists

surveyed in 2013 by the OECD, 97% responded that they were governed by a code of

conduct drawn up by a business, a lobbyists’ association, or the government (Box 1).

Most were also of the opinion that their code provided clear guidance and principles that

were easily applied to specific situations.

Similarly, lobbyists have made it their own duty to foster a culture of integrity in their

profession through awareness raising and training initiatives. Although 86% of the

lobbyists surveyed by the OECD had received training, none had received any from their

governments.

Box 1. Lobbyists’ associations’ codes of conduct: the Association of Government Relations

Professionals and the European Public Affairs Consultancies’ Association

The codes of conduct established by lobbyists associations’ generally specify that lobbyists should provide

truthful information when interacting with officials and not cause public officials to violate any laws, rules, or

regulations.

The code of ethics of the Association of Government Relations Professionals (formerly the American League

of Lobbyists) asserts that a lobbyist should conduct lobbying activities with honesty and integrity. Article 1.2 states:

“If a lobbyist determines that the lobbyist has provided a public official or other interested person with factually

inaccurate information … the lobbyist should promptly provide the factually accurate information to the interested

person.” The code also stipulates that a lobbyist should not cause public officials to violate any law, regulation, or

rule applicable to them.

The Code of Conduct of the European Public Affairs Consultancies' Association (EPACA) similarly establishes

that, when lobbying, “public affairs practitioners … shall neither directly nor indirectly offer or give any financial

inducement to any elected or appointed public official, or staff of their institutions and political groups, nor propose

nor undertake any action which would constitute an improper influence on them”.

Sources: Association of Government Relations Professionals, Code of Ethics, http://grprofessionals.org/join-all/code-of-

ethics; EPACA (European Public Affairs Consultancies' Association), Code of Conduct,

www.epaca.org/uploads/Code_of_Conduct_-_adopted_2013.pdf.

However, there are still gaps in lobbyists’ compliance strategies. The enforcement of

integrity standards and codes of conduct remains relatively low and most lobbyists

surveyed by the OECD indicate that there are either no sanctions for breaching standards

or codes of conduct or, if there are, they are not compelling enough to deter breaches.

http://grprofessionals.org/join-all/code-of-ethics


http://www.epaca.org/uploads/Code_of_Conduct_-_adopted_2013.pdf




The OECD’s review of how countries have implemented the Recommendation over

the last three years reveals an emerging sense that there should be greater focus on the

responsibility of those who are lobbied, namely public officials. They are the guardians of

the public interest and, although it takes two to lobby, it is ultimately incumbent on them

to safeguard the public interest and reject undue influence. Slovenia, for example, makes

public officials responsible for registering any meetings they may have with a lobbyist

(Box 2). Other countries have made deliberate policy decisions to place the registration

and reporting onus solely on lobbyists, rather than public officials. There are a number of

rationales for this, including ensuring that the lobbying industry (and not taxpayers) pays

as much of the cost of its own regulation as possible, the fact that public officials are not

well-placed to provide information about lobbyists and their clients, and to avoid a

chilling effect on public officials meeting with outside parties.

Box 2. The requirement for all Slovenian public officials to report meetings with lobbyists

Although it is up to the lobbyist to register in order to work in Slovenia, the responsibility for reporting any

meetings with public officials lies with the official him- or herself. Any official who has dealings with a lobbyist is

required to record:

the name of the lobbyist;

information on whether the lobbyist has identified him- or herself in accordance with the provisions of

the Integrity and Prevention of Corruption Act;

the area of lobbying;

the name of the interest group or any other organisation for which the lobbyist is lobbying;

any enclosure;

the date and place of the visit by the lobbyist;

and the signature of the person lobbied.

The person lobbied should forward a copy of the record to his or her superior and the Commission for the

Prevention of Corruption within three days. The Commission keeps these records for 5 years. Article 24 of the act

also states that any public official who has reasonable grounds to believe that he or she has been requested to

engage in illegal or unethical conduct may report it to his or her superior or to the person authorised by the superior.

Source: Government of Slovenia (2010), Slovenian Integrity and Prevention of Corruption Act, www.kpk-

rs.si/upload/t_datoteke/ZintPK-ENG.pdf.

The “revolving door” is a major risk to the integrity of public decision making

The OECD’s review of how the Recommendation has been implemented shows that, in

the last three years, an issue of increasing concern has been the practice of

“revolving doors” – the movement of staff between related public and private sectors – and

its negative effects on trust in the public sector. It was the risk most commonly cited by

lobbyists, while legislators also listed it as an emerging threat to transparency and integrity.

Legislators leaving the public for the private sector is not the only issue. It is also

problematic when former assistants to members of parliament and other parliamentary staff

start working as lobbyists.

http://www.kpk-rs.si/upload/t_datoteke/ZintPK-ENG.pdf





The revolving door is not new and appears to be a practice in all countries surveyed

by the OECD. Indeed, as many as a quarter of lobbyists had previously held positions in

the public sector, according to respondents. Most said they had held senior managerial or

advisory positions in ministries, working as ministerial advisors, managers and heads of

parliamentary staff, and advisors to prime ministers. For example, in the United States,

movement between Congress and “K Street”6 has increased dramatically. Three percent

of retiring Members of Congress became lobbyists in 1974. By 2012, that number had

risen to 42% among members of the House of Representatives and 50% among senators

(Gerson, 2012).

Movement between the public and the private sectors can be mutually beneficial,

contributing to the development of personnel and improved organisational competencies

(Äijälä, 2001). However, it also heightens exposure to conflicts of interest and impropriety

(the misuse of insider information, position, and contacts). In post-public service

employment a further risk is “switching sides” – when a public official joins the private

sector to work in the particular field in which he or she worked as a public servant (Box 3).

Box 3. Financial gains for lobbyists with connections to serving politicians

A study from 2010 showed that lobbyists who had previously worked in the office of a US senator suffered a

24% drop in generated revenue when the senator left office and that ex-staffers’ lobbying revenue dropped by 50%

in a single semester after their employers had left the Senate. The study found that “lobbyists are able to cash in on

their connections” and that “being connected to a powerful politician is a key determinant of the demand for a

lobbyist’s services”. Moreover, lobbyists connected to serving politicians earned significantly higher revenues, with

ex-staffers working for serving senators estimated to earn 63% more than those with no such connections.

Source: Blanes I Vidal, J., M. Draca, C. Fons-Rosen (2010), “Revolving door lobbyists”, CEP Discussion Papers, No. 0993,

Centre for Economic Performance, London School of Economics and Political Science, London, p. 18.,

http://eprints.lse.ac.uk/31546/1/dp0993.pdf.

Concern over revolving doors has prompted countries to take measures to prevent and

contain conflict of interest in pre- and post-public employment situations in order to

ensure the integrity of present and former public officials (Table 2). Australia, Canada,

Chile, Slovenia, and Norway, for instance, have a “cooling-off” period, during which

former public officials are not to lobby their former government organisations (Box 4)

(OECD, 2010). In the European Union (EU), the 2013 Staff Regulations for officials and

the terms of employment of other EU servants establish a 12-month cooling-off period for

senior officials (European Parliament, 2013b).

6 K Street in Washington D.C. is known as a centre for numerous think tanks, lobbyists and advocacy groups. It has become

a byword for Washington D.C.’s lobbying industry.

http://eprints.lse.ac.uk/31546/1/dp0993.pdf




Table 2. Restrictions in place on public officials engaging in lobbying activities after leaving public sector

Notes: In Finland, there are general rules on post-employment secrecy. The Ministry of Finance has issued

guidelines for public-sector employment contracts and for evaluating the need for a cooling-off period when a

public servant resigns.

New Zealand has no general restrictions. However, some employment contracts may have a restraint of trade

clause forbidding the use of certain information.

Norway has general post-employment regulations and regulations on secrecy in place.

Slovenia bans public officials from lobbying for two years after they leave office.

In Sweden, officials bound by confidentiality of information rules continue to be so even after their employment

terminates.


Yes, for senior public

officials in the executive

branch

Yes, for senior public

officials in the legislative

branch

Yes, for public officials in

the executive branch

Yes, for public officials in

the legislative branch

Austria

Belgium

Canada l l l l

Chile l l

Estonia

Finland

France l l

Germany l l l l

Hungary

Ireland l l

Italy l l

Korea l l l l

Luxembourg

Mexico l l l l

Netherlands l l

New Zealand

Norway

Poland

Portugal l l l l

Slovenia l l

Spain l

Sweden

Switzerland

United States l l l l

Brazil l

Total OECD24

l Yes 12 8 10 7

No 12 16 14 17




Box 4. Post-public employment restrictions in selected OECD member countries

A number of countries use cooling-off periods as their main tool for addressing post-public employment

concerns. During such periods, public officials are generally not allowed to lobby their previous employers.

Article 7 of Australia’s Lobbying Code of Conduct establishes a cooling-off period of 18 months for ministers

and Parliamentary secretaries and 12 months for ministerial staff. During the period, they are forbidden from

engaging in lobbying activities relating to any matter on which they worked in their official capacities.

The United Kingdom’s Ministerial Code prohibits ministers from lobbying the government for two years after

they leave office.

In Chile, public officials in the executive branch of government are prohibited for a period of six months from

working in or for companies that were under the supervision and control of the public body in which they were

previously employed.

Article 56 of Slovenia’s Integrity and Prevention of Corruption Act establishes that officials may not lobby until

two years have elapsed after they left office. Similarly, Article 36 stipulates that an official may not act as a

representative of a business entity that has established or is about to establish business contacts with the body in

which he or she held office until two years have passed since he or she left office.

In Canada, there are similar post-public employment restrictions, though the cooling-off period is considerably

longer. For a period of five years after they cease to be designated public office holders, Article 10.11(1) of the

Canadian Lobbying Act prohibits designated public office holder from:

(a) communicating with a public office holder in respect of:

i) the development of any legislative proposal by the Government of Canada or by a member of the Senate or

the House of Commons;

ii) the introduction of any Bill or resolution in either House of Parliament or the passage, defeat or amendment

of any Bill or resolution that is before either House of Parliament;

iii) the making or amendment of any regulation as defined in subsection 2(1) of the Statutory Instruments Act;

iv) the development or amendment of any policy or program of the Government of Canada;

v) the awarding of any grant, contribution or other financial benefit by or on behalf of Her Majesty in right of

Canada, or

vi) the awarding of any contract by or on behalf of Her Majesty in right of Canada;

or (b) to arrange a meeting between a public office holder and any other person.

The activities listed are covered under the ban if they are carried out for remuneration and apply to consultant

lobbying.

Source: Australian Government, Lobbying Code of Conduct, http://lobbyists.pmc.gov.au/conduct_code.cfm; UK

Government’s Cabinet Office, Ministerial Code, Article 7.25,

www.gov.uk/government/uploads/system/uploads/attachment_data/file/61402/ministerial-code-may-2010.pdf; Slovenian

Government, Integrity and Prevention of Corruption Act, www.kpk-rs.si/upload/t_datoteke/ZintPK-ENG.pdf; Federal

Government of Canadian, Lobbying Act (R.S.C., 1985, C. 44 (4th Supp.); OECD 2013 Survey on Lobbying Rules and

Guidelines.

http://lobbyists.pmc.gov.au/conduct_code.cfm

http://www.gov.uk/government/uploads/system/uploads/attachment_data/file/61402/ministerial-code-may-2010.pdf





In legislatures – be they Parliament or Congress – where the impact of lobbyists can

be particularly acute, there is a need for greater safeguards. However, as many as 74% of

surveyed legislators responded that their countries had no restrictions in place for

controlling legislators’ lobbying activities after they left office (Figure 9).

Figure 9. Generally, no restrictions (e.g. cooling-off periods) are in place to control legislators who

engage in lobbying activities after leaving a legislature

Note: Respondents were asked “After a Parliamentarian leaves Parliament/Congress, are there

restrictions in place (e.g. a “cooling-off” period) for engaging in lobbying activities?”

Source: OECD 2013 Survey on Lobbying for Legislators.

In addition to cooling-off periods, governments may require public officials to

disclose offers of future employment where there is a risk of conflict of interest and to

seek permission before accepting the offer. Approving decisions on post-public

employment is generally the responsibility of senior management in public organisations.

In the UK, the Business Appointment Rules for Civil Servants require most senior civil

servants to obtain permission before they take up business appointments.7

Similarly, according to the UK’s Ministerial Code, ministers must seek advice from the

independent Advisory Committee on Business Appointments in the two years after they

leave office about any appointment or employment they wish to take up.8 In Norway, if

transition contravenes post-employment regulations, politicians who are considering

accepting a new job, taking up a position outside the public service, or starting a business

should disclose to the Committee on Outside Political Appointments the requisite

information at least two weeks before commencing their new position (OECD, 2010).

7 Available at:

http://acoba.independent.gov.uk/media/25653/business%20appointment%20rules%20for%20civil%20servants%20feb%20

2011.pdf.

8 Article 7.25 of the Ministerial Code at www.gov.uk/government/uploads/system/uploads/attachment_data/file/61402/ministerial-code-may-2010.pdf.

5% 5%

16%

74%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Yes, there arerestrictions but they

are too restrictive

Yes, there arerestrictions and they

are sufficientlyrestrictive

Yes, there arerestrictions but theyare not sufficiently

restrictive

No, there are norestrictions

http://acoba.independent.gov.uk/media/25653/business%20appointment%20rules%20for%20civil%20servants%20feb%202011.pdf

http://acoba.independent.gov.uk/media/25653/business%20appointment%20rules%20for%20civil%20servants%20feb%202011.pdf

http://www.gov.uk/government/uploads/system/uploads/attachment_data/file/61402/ministerial-code-may-2010.pdf




Only 25% of surveyed OECD members require officials to obtain permission before

taking up a private-sector appointment where they may lobby their previous colleagues.

This minority requirement was further confirmed by legislators, the vast majority of

whom (79%) responded that they did not have to obtain permission before transferring to

such a position.

While many OECD members have introduced some form of restriction on public

officials’ post-public employment, they have paid the issue of pre-public employment

little attention. Less than one-third of surveyed OECD Member countries place

restrictions on hiring lobbyists to fill a regulatory or advisory post in government

(Figure 10).

Figure 10. Restrictions on hiring lobbyists to fill a regulatory or advisory post in government in OECD

countries


As many as 46% of surveyed lobbyists said that there were no restrictions in place.

Over a quarter of them (28%) know if there were any restrictions on employing lobbyists

for regulatory or advisory positions in government.

Countries that address pre-public employment concerns may do so either by requiring

officials to cease their previous activities or by limiting the activities or projects in which

new employees can participate. Slovenia prohibits anyone being hired for a post in

government to remain registered as a lobbyist. In Sweden, however, general conflict of

interest rules do not typically restrict the hiring of job applicants because of their

professional background, though they might limit the type of decisions they could be

involved in making. At the European Union (EU) level, the appointing authority has to

examine whether a candidate for a position as an official has “any personal




interest such as to impair his independence or any other conflict of interest”

(European Parliament, 2013b). The candidate has to declare any actual or potential

conflict of interest to the appointing authority.

Insider lobbying: influence of private interests through advisory groups is an

emerging concern

An advisory group is a body put in place by the executive or legislative branches of

government to provide advice, expertise, or recommendations. Such groups comprise

public- and/or private-sector members and/or representatives from civil society. In OECD

member countries, these advisory groups go under many different names. Australia refers

to them as Advisory Committees or Consultative Committees, while the United Kingdom

calls them Advisory Committees, Advisory Councils or Advisory Boards.

OECD governments make wide use of advisory groups: over 82% of OECD members

said they regularly consult advisory groups when drafting primary laws.

Most OECD countries require membership, agendas, minutes, participants'

submissions and other information relating to advisory groups to be made publicly

available so that stakeholders can scrutinise their work. Nevertheless, the OECD’s review

shows that a serious emerging risk to the integrity of public decision making is the

influence of private interests vested in advisory groups. When, for example, corporate

executives or lobbyists advise governments as members of an advisory group, they are no

longer external lobbyists, but actors who are part of the decision-making process and

have direct access to decision makers. As many as 79% of surveyed legislators believe

that such groups exert influence on public decision-making processes and outcomes.

Moreover, almost half (47%) believe that they are driven by special interests, not by the

interests of the public or society at large. One example of the response to the risk of

expert groups being captured by special interests is the debate in the EU (Box 5).




Box 5. The debate on the risk of capture of EU expert groups by special interests

Reflecting growing concern over the presence of lobbyists and corporate executives in expert groups, low

levels of transparency, and problematic practices, Members of the European Parliament (MEPs) voted in favour of

freezing part of the budget for the Commission’s expert groups until new rules were introduced to safeguard against

capture by special interests and to improve transparency. The freeze was lifted one year later in September 2012

when the Commission committed to address concerns over expert groups across all DGs and to enter into an

informal dialogue to draw up guidelines for all new groups.

In parallel, the European Court of Auditors concluded that, of the agencies they reviewed, none of those

working on vital decisions affecting the safety and health of consumers adequately managed their experts’ conflict

of interest situations. The shortcomings identified were, however, of varying degrees. In the audit of the European

Food Safety Authority (EFSA), for example, the Court of Auditors found that experts were advocates and reviewers

of the same concepts. As a result, the scientific experts played conflicting roles and most of the members of one of

EFSA’s scientific bodies had been advocates of a concept (through previous publications, participation in

workshops and expert groups, etc.) which had been subject to analysis by the same scientific body. In another case,

two EFSA experts were simultaneously advising a private organisation while reviewing the same concept as

members of the EFSA scientific body. In both cases, EFSA concluded that there was no conflict of interest.

In its 2013 report on the discharge of EFSA’s budget for the financial year 2011, the European Parliament

noted that EFSA had taken a number of steps following the Court of Auditors' audit. They included: introducing a

comprehensive framework for avoiding potential conflicts of interest in 2007 and thereafter regularly reviewing and

updating it; appointing an ethics adviser in 2012; applying the framework proposed by the Commission on Ethics

and Integrity; and adopting a specific gift policy in July 2012. Although the Parliament acknowledged EFSA's

efforts to improve its prevention and management of conflict of interests, it noted that the independence and

competence of its external experts remain questioned by fellow food safety experts and watchdog NGOs. EFSA has

scheduled an evaluation of its independence policy to be completed by the end of 2013.

Sources: European Parliament, 2012 Budgetary Procedure Conciliation Document – Joint Text, Doc No 4-19-11-2011,

amended by budget line, Consolidated Document. p. 17,

www.europarl.europa.eu/document/activities/cont/201112/20111206ATT33432/20111206ATT33432EN.pdf; Banks, M.

(2011), “NGO welcomes move to block funding for EU 'expert groups'”, The Parliament, online journal, 1st November,

www.theparliament.com/latest-news/article/newsarticle/ngo-welcomes-move-to-block-funding-for-eu-expert-

groups/#.UfDgee5KQwq; European Court of Auditors (2012) Management of Conflict of Interests in Selected EU Agencies,

Special Report No. 15, Publications Office of the European Union, Luxembourg,

http://eca.europa.eu/portal/pls/portal/docs/1/17190743.PDF; European Parliament Resolution of 17 April 2013 with

observations forming an integral part of its Decision on the discharge of the budget of the European Food Safety Authority

for the financial year 2011 (C7-0258/2012 – 2012/2196(DEC)) www.europarl.europa.eu/sides/getDoc.do?pubRef=-

//EP//NONSGML+TA+P7-TA-2013-0146+0+DOC+PDF+V0//EN.

The majority of OECD countries (79%) indicated that there was no obligation to

balance numbers of private sector and civil society representatives in advisory groups.

There were also few restrictions when it came to which actors were allowed to sit as

members in advisory groups. Lobbyists were allowed to sit in, in a personal capacity in

79% of respondent countries while corporate executives could attend these sessions in

92% of these cases (Figure 11).

http://www.europarl.europa.eu/document/activities/cont/201112/20111206ATT33432/20111206ATT33432EN.pdf

http://www.theparliament.com/latest-news/article/newsarticle/ngo-welcomes-move-to-block-funding-for-eu-expert-groups/#.UfDgee5KQwq


http://eca.europa.eu/portal/pls/portal/docs/1/17190743.PDF

http://www.europarl.europa.eu/sides/getDoc.do?pubRef=-//EP//NONSGML+TA+P7-TA-2013-0146+0+DOC+PDF+V0//EN





Figure 11. Advisory groups: a balanced composition of interests?

Note: Data in the graph present an aggregate of information provided by Austria, Belgium, Canada,

Chile, Estonia, Finland, France, Germany, Hungary, Ireland, the Italian Ministry of Agriculture,

Korea, Luxembourg, Mexico, the Netherlands, New Zealand, Norway, Poland, Portugal, Slovenia,

Spain, Sweden, Switzerland, and the United States.


Evidence shows that having lobbyists as members of advisory groups is common

practice. The vast majority of lobbyists surveyed by the OECD (78%) responded that they

were allowed to sit in on advisory groups in a personal capacity. Approximately one-fifth

(18%) of lobbyists questioned were currently doing so (Figure 12). However, concerns

over the composition of advisory groups – in particular that lobbyists should be

members – could be dealt with by making membership information publicly available.

Canada’s Lobbying Act, for example, allows the public to ascertain whether any member

of an advisory group is also a lobbyist. Consequently, any decision to appoint a lobbyist

to an advisory group becomes a matter of political and/or public judgement.

Half of the legislators questioned were of the opinion that lobbyists should not be

allowed to sit in on advisory groups in a personal capacity, and 47% of surveyed

legislators believed that the same should apply to corporate executives.

21%

79%

92%

0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%

There is an obligation to have a balanced composition(between for example private-sector and civil society

representatives) of advisory/expert groups

Lobbyists are allowed to sit in advisory/expert groups inpersonal capacity

Corporate executives are allowed to sit in advisory/expertgroups in personal capacity




Figure 12. Lobbyists are allowed to sit in on government and Parliamentary advisory/expert groups in

a personal capacity

Note: Respondents were asked the question “Are lobbyists allowed to sit in government advisory groups or

Parliamentary advisory/expert groups in a personal capacity?”

Source: OECD 2013 Survey on Lobbying for Lobbyists.

Measuring the costs and benefits of enhancing transparency and integrity in

lobbying remains a challenge

Compliance is a particular challenge for countries when – by increasing transparency,

for example – they seek to address rising concern over lobbying. Setting clear,

enforceable rules and guidelines is necessary but not sufficient. Ensuring compliance and

deterring and detecting breaches requires a coherent spectrum of strategies and

mechanisms, which includes a system of monitoring and enforcement. Not only would

such a system strengthen compliance, but it would also allow governments to carefully

balance the cost and benefits of the system and identify effective measures to address

concerns.

All components of good governance require assessment and data. Lobbying is no

exception. Yet, most countries still struggle to measure the costs and benefits of

enhancing transparency and integrity in lobbying. To better understand lobbying in

different country contexts, it is of the utmost importance to gather data on costs for

governments and lobbyists as well as on such benefits as greater trust in government and

better informed, balanced, effective policies. Although technology considerably reduces

the burden of collecting and analysing data, there is still little quantitative data available

today.

18%

60%

22%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Yes, lobbyists are and I amcurrently sitting on a government

advisory/expert groups orParliamentary advisory/expertgroups in a personal capacity

Yes, lobbyists are and but I ampersonally not sitting on a

government advisory/expertgroups or Parliamentary

advisory/expert groups in apersonal capacity

No

IV. THE WAY FORWARD: CAPITALISING ON THE OECD PRINCIPLES – 37



IV. The way forward: capitalising on the OECD principles to further

reinforce a fair and inclusive decision-making process

The review of how countries have implemented the Recommendation on Principles for

Transparency and Integrity in Lobbying shows that OECD members, key partners, and

other partner countries have used it as a benchmark in designing or revising lobbying

regulations and public decision-making processes. The approach and content of the

Recommendation has proven applicable across different countries, ranging from Austria,

Australia, Chile, and Canada to Hungary, Ireland, Poland, Slovenia, and the

United Kingdom. In countries with no lobbying regulations in place, the Recommendation

has shaped the debate on policy options to address the risks and concerns related to the

transparency and integrity of lobbying in countries like Brazil and Portugal.

Yet, while the Recommendation is relevant as a guiding reference for the public

decision-making process, the review of countries’ experiences over the past three years

reveals that evolving public decision making and lobbying practices have spawned new

risks which could weaken citizens’ trust in government and compromise fair decision-

making. Such risks warrant special attention. The following key recommendations were

therefore approved by the OECD Council in March 2014.

Continue efforts to address lobbying concerns and risks in the decision-making

process as a key policy lever for fostering trust

The OECD’s work on a Forward-Looking Agenda on Trust identifies public trust as

the cornerstone of effective governance and what legitimises the authority of the state

over individuals. Trust in government is also necessary for economic growth and social

progress. Yet, citizens’ trust in government is declining. Efforts to make the public

decision-making process more reliable, fairer, and transparent can contribute to restoring

trust.

Lobbying practices lie at the heart of identified concerns and risks. Citizens, civil

society, and businesses have a right to know who is influencing the public decision-

making process. Transparency in lobbying would help promote a level playing field,

informed participation, and accountability.

The Recommendation has already guided many countries in designing or revising

lobbying regulations. Efforts to support the implementation of the Recommendation

could strengthen confidence in the public decision-making process and restore trust in

government. Moving forward, it is essential to keep up those efforts and to review and

address the challenges that countries currently face – such as who should be covered by

lobbying regulations – and analyse the effectiveness of implementing alternative integrity

measures – such as the transparency of decision makers’ agendas – in addressing

lobbying concerns. To follow up the continued implementation of the Recommendation, a

valuable contribution will be for the Public Governance Committee (PGC) to report back

to the Council on Principles for Transparency and Integrity in Lobbying within the next

three years.

38 – IV. THE WAY FORWARD: CAPITALISING ON THE OECD PRINCIPLES



The wider implications of integrity in the public decision-making process also need to

be considered. Risks to integrity from undue influence are connected to a wide variety of

policy communities. Input from them could contribute to developing innovative data and

additional tools to address common concerns. For example, as stated earlier, undue

influence in and capture of the public decision-making process harm competition. It is

therefore essential to reach out to other policy communities (e.g. Competition) in order to

grasp the full spectrum of implications and identify sector-based approaches which, when

combined, may produce comprehensive solutions. The OECD’s relevant committees

(e.g. Regulatory Policy Committee, Competition Committee, Corporate Governance

Committee) should combine their efforts to develop innovative tools that effectively

address common concerns and provide the evidence necessary to continue informing

current debate in member, key partner, and other partner countries.

Invest in measuring benefits and costs and monitoring performance

Collecting evidence and data that relate to lobbying, the public decision-making

process and, ultimately, the broader integrity framework is essential to identifying

benefits, measuring costs, and monitoring performance. Since implementing measures to

make lobbying more transparent and decision making fairer is not without cost, it is

crucial to evaluate whether such measures meet intended objectives or whether money

could be better spent elsewhere.

Findings from the review point to data collection being a major challenge for

countries. Currently, limited data are collected in these areas and the data that are

available are inconsistent and incomparable. It is necessary to develop a set of relevant

data, benchmarks, and indicators to enable governments to measure the impact of their

integrity policies, particularly on lobbying and the public decision-making process.

The collection of relevant, credible data to support evidence-based policy making should

also be co-ordinated with other policy communities in order to address mutual concerns.

Identify and promote innovative integrity frameworks that reflect the needs and

concerns of countries in the 21st century

The review of member countries’ implementation of the Recommendation showed

that many rely heavily, and at times solely, on their integrity framework to safeguard the

public interest and mitigate risks related to the public decision-making process. In that

regard, a sound integrity framework indeed remains essential. However, integrity risks

are evolving and so should integrity frameworks.

In 1998, the OECD Council adopted a Recommendation on Improving Ethical

Conduct in the Public Service which contains the Principles for Managing Ethics in the

Public Service that have helped countries design, review, and implement an integrity

framework. The Principles have guided OECD work in the area of public sector integrity

for the past fifteen years, but recent experiences – such as the Public Sector Integrity

Review of Italy (OECD, 2013b) – demonstrated that practices in the public sector are

changing. These changing practices, together with globalisation and the emergence of

transnational lobbying, have led to new concerns being raised. Countries are facing new

challenges and constraints that require them to regularly review and adapt their integrity

frameworks.

Ministers at the 2013 Ministerial Council Meeting reaffirmed the OECD’s role as a

global standard-setter and called on the Organisation to proactively update and upgrade

IV. THE WAY FORWARD: CAPITALISING ON THE OECD PRINCIPLES – 39



its existing standards and respond to any gaps in global standard setting where

appropriate. In that light and in order to support countries’ work, the 1998 Principles will

therefore be reviewed to ensure that they accurately reflect the needs of countries in the

21st century. Updating the Principles will not only help countries strengthen the

transparency and integrity of their public decision-making processes, it will also provide a

whole-of-government integrity framework applicable to all stages of the policy cycle.

Review policies for managing conflict of interest in revolving door practices and the

unbalanced representation and influence of advisory groups

The review of countries’ implementation of the Recommendation on Principles for

Transparency and Integrity in Lobbying revealed that risks and concerns are evolving.

They need to be matched with effective policies and practices to safeguard the integrity of

the public decision-making process.

In the past decade, the OECD has led the way in supporting countries in their efforts

to introduce and implement systems for managing conflict of interest in the public sector.

However, evolving lobbying practices have created new risks or intensified existing ones,

particularly in areas where conflict of interest management systems present shortcomings.

Two such areas are concerns over revolving door practices in pre- and post-public

employment and the unbalanced representation and influence of advisory groups.

Interaction (i.e. offering expert advice, expertise or recommendations through

advisory groups) and movement between the public and the private sectors (i.e. by public

officials taking up positions in the private sector or vice versa) can be mutually beneficial.

They may help to improve organisational competencies and the quality of decisions.

However, this mutual interplay also increases exposure to the risks of misuse of insider

information and the abuse of position and connections. It jeopardises the integrity of

public decision making when advisory groups are dominated by certain private interests

and heightens risks of conflict of interest.

Focusing efforts on revolving doors and advisory groups could help to develop

alternative ways of addressing the attendant risks and contribute to safeguarding the

fairness of the public decision-making process.

BIBLIOGRAPHY – 41



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Lobbyists, Governments and Public TrustVoLume 3

ImPLemenTInG The oeCD PrInCIPLes for TransParenCy anD InTeGrITy In LobbyInG

Lobbyists, Governments and Public TrustVoLume 3ImPLemenTInG The oeCD PrInCIPLes for TransParenCy anD InTeGrITy In LobbyInG

HIGHLIGHTS

Contents

Foreword

Acknowledgments

Executive summary

Why address lobbying risks and concerns now?

Governments are shedding more light on lobbying

Addressing emerging concerns on integrity

The way forward: capitalising on the OECD principles to further reinforce a fair and inclusive decision-making process

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HIGHLIGHTS

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